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Interest Income Withholding for US Non Residents

 

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Subject Author Date
Interest Income Withholding for US Non Residents W 06-06-2009
Posted by W on June 6, 2009, 2:02 pm
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An earlier post here suggested a person residing less than 183 days per year
in the U.S., who makes interest income, would have either 0% or 30%
withholding, depending on the type of interest income. I wanted to get
examples of each type of interest withholding.

The original post here stated that one should read Code § 871(a) for the
general rule that U.S. source interest income paid to non-U.S. persons is
subject to a 30% tax. There are exceptions in Code 871(h) and (i) for bank
interest and portfolio interest, among others.

The exception for bank interest is clear. Would this include money market
interest as well?

It's not clear what is Portfolio interest. Would this include interest
from bond investments?

What are some other examples of interest income that would get the 0%
withholding rate?

And what are some examples of interest income that would get the automatic
30% withholding?

If there is a good summary list of types of incomes for laymen readers
someplace, I would appreciate the reference.

--
W

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Posted by Alan on June 6, 2009, 3:05 pm
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W wrote:
> An earlier post here suggested a person residing less than 183 days per year
> in the U.S., who makes interest income, would have either 0% or 30%
> withholding, depending on the type of interest income. I wanted to get
> examples of each type of interest withholding.
>
> The original post here stated that one should read Code § 871(a) for the
> general rule that U.S. source interest income paid to non-U.S. persons is
> subject to a 30% tax. There are exceptions in Code 871(h) and (i) for bank
> interest and portfolio interest, among others.
>
> The exception for bank interest is clear. Would this include money market
> interest as well?
>
> It's not clear what is Portfolio interest. Would this include interest
> from bond investments?
>
> What are some other examples of interest income that would get the 0%
> withholding rate?
>
> And what are some examples of interest income that would get the automatic
> 30% withholding?
>
> If there is a good summary list of types of incomes for laymen readers
> someplace, I would appreciate the reference.
>
General Info:
http://www.irs.gov/businesses/small/international/article/0,,id=105154,00.html

Interest Details:
http://www.irs.gov/businesses/small/international/article/0,,id=106355,00.html

Also note that there are at least two kinds of money market
interest. Interest from MMAs (Money Market Accounts) and interest
(reported as dividends) from MMMFs (Money Market Mutual Funds).
The former is bank interest; the latter is portfolio interest.

--
<< ------------------------------------------------------- >>
<< The foregoing was not intended or written to be used, >>
<< nor can it used, for the purpose of avoiding penalties >>
<< that may be imposed upon the taxpayer. >>
<< >>
<< The Charter and the Guidelines for submitting posts >>
<< to this newsgroup as well as our anti-spamming policy >>
<< are at www.asktax.org. >>
<< Copyright (2007) - All rights reserved. >>
<< ------------------------------------------------------- >>

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